An Unbelievable Conflict of Interest

Law in forty-seven U.S. States require the government authority State Department of Agriculture to enforce pet food regulations. These same forty-seven States send government representatives to participate in the Association of American Feed Control Officials (AAFCO) process which writes pet food/animal feed laws and defines all pet food/animal feed ingredients. Forty-seven U.S. States recognize a government authority should be charged with the responsibility of writing and enforcing law.

The three remaining U.S. States – Kentucky, Indiana, and Texas – have provided the significant responsibility of pet food enforcement and law development to universities; University of Kentucky, Purdue University, and Texas A&M University.

Kentucky

Kentucky law states pet food and animal feed regulations “shall be administered by the director of the Kentucky Agricultural Experiment Station of the State of Kentucky”. The ‘Kentucky Agricultural Experiment Station’ – the authority that enforces pet food law in Kentucky – is part of the University of Kentucky. Quoting further Kentucky law“The College of Agriculture of the University of Kentucky shall constitute the Agricultural Experiment Station.”

In other words, a university that accepts donations from the pet food industry is charged with enforcing pet food and animal feed law in Kentucky. In Kentucky, pet food law enforcement is not performed by a government agency (such as the Kentucky Department of Agriculture), in Kentucky pet food law is enforced by University of Kentucky employees.

On the University of Kentucky website, the College of Agriculture “Departments” webpage evidences the University is indeed charged with regulatory authority:

The “Regulatory Services Department” within the University of Kentucky College of Agriculture Mission Statement: “As a part of the Kentucky Agricultural Experiment Station in the UK College of Agriculture, Regulatory Services is committed to service and consumer protection of Kentucky citizens, businesses, and industries.”

Pet food law in Kentucky is not enforced by a government entity…
such as the state’s Department of Agriculture…

Pet food law in Kentucky is enforced by a university.

Of concern, the University of Kentucky College of Agriculture Division of Regulatory Services has a “Advisory Board” that includes a significant number of industry representatives…

Eleven of the thirteen member Kentucky Regulatory Services advisory board are from industry. Griffin Industries – a rendering company part of the largest rendering firm in the US – and Alltech – an animal feed and pet food nutrition company – each have two members on the Kentucky Regulatory advisory board. (More on Alltech below.)

But it gets worse…

Not only do University of Kentucky College of Agriculture employees enforce law…THEY ALSO WRITE LAW.

University of Kentucky College of Agriculture employees – a public university that accepts donations from industry – are active members of the Association of American Feed Control Officials (AAFCO). AAFCO writes pet food and animal feed laws and ingredient definitions.

Is there a conflict of interest?

Looking back to the University of Kentucky website for potential conflicts of interest, on the “Industry Sponsor Agreement” page the university proudly states “Industry-funded research and technology transfer at the University of Kentucky have accelerated at an unprecedented pace over the past few years.” However the sponsor information stops there. The University of Kentucky“Sponsored Products Search Portal” is password protected. The public is not provided free access to learn exactly who donates to the university and how much is donated.

Just one example of a pet food manufacturer funding pet food research at University of Kentucky is found on the AVMA website; “In vivo measurement of flatulence and nutrient digestibility in dogs fed poultry by-product meal, conventional soybean meal, and low-oligosaccharide low-phytate soybean meal.” Two University of Kentucky scientists partnered with Hill’s Pet Nutrition to publish this research.

Looking at the AAFCO website for potential conflicts of interest, the Biography page for Kristen Green (University of Kentucky Regulatory Services employee, Chair of the AAFCO Pet Food Committee, and AAFCO Board of Director member)…

She has worked with the University of Kentucky as a Registration Specialist for the Division of Regulatory Services since 2012.

She received her B.A. and M.A. from the University of Kentucky. Prior to her position with the Division of Regulatory Services, she worked for 5 years managing international animal feed registrations for Alltech, Inc.

2012 Ms. Green leaves her employment at Alltech (a pet food and animal feed ingredient company) and is employed by the University of Kentucky Division of Regulatory Services.

August 2012 Ms. Green becomes a member of the AAFCO Pet Food Committee, her first AAFCO meeting as a regulatory authority (all regulatory authorities can become members of AAFCO committees).

January 2013 Five months later, at her second meeting as a regulatory authority Ms. Green becomes “Vice Chair” of the Pet Food Committee.

2016 Ms. Green becomes a member of the AAFCO Board of Directors, staged to become AAFCO President in coming years.

2018 Ms. Green’s previous employer, Alltech, Inc., holds two advisory positions to the University of Kentucky Division of Regulatory Services – the division of University of Kentucky College of Agriculture that she currently works for.

Questions to pet owners: Is it a conflict of interest for a university – that clearly has relationships with industry – to write and enforce law? Does industry donations to and research projects with the University of Kentucky, influence the Kentucky Division of Regulatory Services? Do corporate advisors to the Kentucky Regulatory Services influence regulation and enforcement?

Unfortunately, there is more to consider. The University of Kentucky is not the only public university that writes and enforces law…

Indiana

Pet food and animal feed regulations in Indiana are not enforced by the state’s government agency – the Department of Agriculture. Instead, in Indiana pet food and animal feed regulations are enforced by Indiana’s Office of Indiana State Chemist – a division of Purdue University. The Office of Indiana State Chemist homepage states: “The Indiana State Chemist is charged with administering several agricultural laws involving animal feeds, fertilizers, pesticides and seeds. The goals of these laws are to ensure truth-in-labeling, food safety, user safety and the protection of our environment.”

And just like with the University of Kentucky, Purdue University employees enforce law and write law.

Purdue University Office of Agricultural Research employees – a public university that accepts donations from the pet food industry – are active members of the Association of American Feed Control Officials (AAFCO) who are charged with writing laws governing pet food and animal feed.

Robert Gieger – a Purdue University Office of Agricultural Research employee, is President-elect of AAFCO and a member of the AAFCO Board of Directors…

“Members of the Purdue Veterinary Medicine Class of 2019 reached a major milestone Sunday afternoon (April 15) as they took part in the College’s White Coat Ceremony held in Stewart Center’s Fowler Hall. Sponsored by Elanco Animal Health and Hill’s Pet Nutrition.“

The “Canine Health Foundation” listed on the Purdue University website as an “External Funding Source” is a foundation affiliated with the American Kennel Club. Provided on the Canine Health Foundation ” Our Partners“ webpage is this…

Purina Pet Food is a ‘Partner’ of Canine Health Foundation who is an ‘External Funding Source’ for Purdue University Veterinary research.

Unfortunately, there is still more to consider. The University of Kentucky and Purdue University are not alone, one more public university writes and enforces law…

Is there a conflict of interest?

“Choosing the right kind of pet food is important for your pet’s health and quality of life. The Pet Nutrition Alliance has developed a website with resources for veterinarians and pet owners, including a nutritional calculator, frequently asked questions, and how to understand pet food labels. This website can be found here.”

This Texas A&M University Veterinary School webpage directs readers to Pet Nutrition Alliance where we find these “Educational Sponsors“…

On the Texas A&M University AgriLife Research (same division of Texas A&M regulatory authority is housed) “About Corporate Relations” page we find some potential conflict of interest language…

And in searching the Texas A&M University Office of the Texas State Chemist (regulatory authority for pet food and animal feed) website we find this division of the university also has an Advisory Board with a large number of industry representatives.

The Advisory Board meets “not less than once a year” with Texas A&M University regulatory authorities to – in part – “answer questions concerning the programs and to receive suggestions from the committee relating to improvements in the administration of the laws.”

Members of the current Texas A&M University Office of the Texas State Chemist Advisory Board include:

Petco Animal Supplies, Inc.

Darling Ingredients Inc. (rending company)

Texas Association of Dairymen

Texas Cattle Feeders Association

Concerning

State law in Kentucky, Indiana, and Texas provide these universities with the liberty to write and enforce pet food law. It is legal.

But is it ethical?

Forty-seven U.S. State Department of Agriculture government agencies charged with enforcement of pet food law are prohibited to accept financial gifts from the pet food industry. But in Kentucky, Indiana, and Texas – things are very different. State law provided these universities the authority to enforce pet food law, and to participate in AAFCO giving them the ability to write pet food law…but State law did not prohibit these universities from accepting donations from the industries they regulate.

Question: If Pet Food Brand A donated $5 million dollars to the Veterinary School at Purdue University, could authorities of the Indiana State Chemist Office – a division of Purdue University – remain unbiased in regulating Pet Food Brand A?

Maybe yes, maybe no. Research tells us no.

Though the quote below was in consideration of conflict of interest issues surrounding the human medical industry, it applies to the concern here as well. Published in the Journal of American Medical Association in 2006 is the publication “Health Industry Practices That Create Conflicts of Interest“…

Social science research demonstrates that the impulse to reciprocate for even small gifts is a powerful influence on people’s behavior. Individuals receiving gifts are often unable to remain objective; they reweigh information and choices in light of the gift. So too, those people who give or accept gifts with no explicit “strings attached” still carry an expectation of some kind of reciprocity. Indeed, researchers suggest that the expectation of reciprocity may be the primary motive for gift-giving. Researchers have specifically studied industry gifts to physicians. Receiving gifts is associated with positive physician attitudes toward pharmaceutical representatives. Physicians who request additions to hospital drug formularies are far more likely to have accepted free meals or travel funds from drug manufacturers. The rate of drug prescriptions by physicians increases substantially after they see sales representatives, attend company-supported symposia, or accept samples. The systematic review of the medical literature on gifting by Wazana found that an overwhelming majority of interactions had negative results on clinical care.

Regulatory enforcement aside, how much influence do University of Kentucky, Purdue University, and Texas A&M University have at AAFCO (the law writing private corporation)?

Below is a graph that displays – per the AAFCO website – the committee participation of University of Kentucky, Purdue University and Texas A&M University as compared to committee participation of an example government agency State Department of Agriculture (Florida – my home state). Each of these AAFCO Committees are responsible for writing “Model Bills” that become state law.

As you can see, employees of these three universities are heavily involved in the pet food/animal feed regulatory process. One or more of each of these universities participate in every AAFCO Committee that writes law.

The question remains…

Do pet food manufacturing donations to

University of Kentucky
Purdue University
and Texas A&M University

influence pet food law and enforcement of pet food law?

For Kentucky, Indiana, and Texas resident pet owners that believe their state universities should NOT be writing and enforcing pet food law, write your Governor and or state Legislators.

Example email Kentucky pet owners:

In 47 U.S. States, pet food regulations are enforced and state laws are written by government agencies. In Kentucky, pet food laws are written and enforced by the University of Kentucky College of Agriculture. University of Kentucky College of Agriculture Regulatory Services writes and enforces pet food laws. Donations from pet food manufacturers are common and extensive to University of Kentucky. It is a concern if Regulatory Services can remain unbiased due to the extent of pet food manufacturing donations to University of Kentucky.

Kentucky law must be changed to move the regulation of pet food/animal feed and the participation in AAFCO to Kentucky Department of Agriculture. Pet food and feed laws should not be written and enforced by a university that accepts financial donations from the very industry it regulates.

Example email Indiana pet owners:

In 47 U.S. States, pet food regulations are enforced and state laws are written by government agencies. In Indiana, pet food laws are written and enforced by Purdue University College of Agriculture. Purdue University College of Agriculture Office of the Indiana State Chemist writes and enforces pet food laws. Donations from pet food manufacturers are common and extensive to Purdue University. It is a concern if the Office of the Indiana State Chemist can remain unbiased due to the extent of pet food manufacturing donations to Purdue University.

Indiana law must be changed to move the regulation of pet food/animal feed and the participation in AAFCO to Indiana Department of Agriculture. Pet food and feed laws should not be written and enforced by a University that accepts financial donations from the very industry it regulates.

Example email Texas pet owners:

In 47 U.S. States, pet food regulations are enforced and state laws are written by government agencies. In Texas, pet food laws are written and enforced by Texas A&M University College of Agriculture. Texas A&M University College of Agriculture Office of the Texas State Chemist writes and enforces pet food laws. Donations from pet food manufacturers are common and extensive to Texas A&M University. It is a concern if the Office of the Texas State Chemist can remain unbiased due to the extent of pet food manufacturing donations to Texas A&M University.

Texas law must be changed to move the regulation of pet food/animal feed and the participation in AAFCO to Texas Department of Agriculture. Pet food and feed laws should not be written and enforced by a university that accepts financial donations from the very industry it regulates.

For pet owners that reside in every other state who believe state universities in Kentucky, Indiana, and Texas should NOT be writing and enforcing pet food law, write your State Department of Agriculture.

Example email:

In 47 U.S. States, pet food regulations are enforced and state laws are written by government agencies. In Kentucky, Indiana and Texas pet food laws are written and enforced by universities. Employees of University of Kentucky, Purdue University and Texas A&M University write and enforces pet food laws. Donations from pet food manufacturers are common and extensive to these universities. It is a concern if these university employees would be influenced by pet food manufacturing donations to their respective university, thus influencing the laws that govern pet food in all US States.

Law should only be written and enforced by a government authority. I understand that [your state] cannot influence law in Kentucky, Indiana, or Texas. But [your state] can insist the American Association of Feed Control Officials (AAFCO) only allow government employees the liberty to write law.

“Social science research demonstrates that the impulse to reciprocate for even small gifts is a powerful influence on people’s behavior. Individuals receiving gifts are often unable to remain objective; they reweigh information and choices in light of the gift.”

Employees of University of Kentucky, Purdue University, and Texas A&M University might have the best of intentions…but due to the large financial gifts from the pet food industry provided to their respective employers, they should NOT be charged with enforcing and/or writing law.

Become a member of our pet food consumer Association. Association for Truth in Pet Food is a a stakeholder organization representing the voice of pet food consumers at AAFCO and with FDA. Your membership helps representatives attend meetings and voice consumer concerns with regulatory authorities. Click Here to learn more.

Related News

Comment18

Ian
Aug 13, 2018

Thank you for publicly “connecting the dots” in the “swamp” that is the pet feed industry essentially self-regulating itself through corporate influence and donations, as well as the revolving door between AAFCO and industry employment.

Wow. Just Wow. I’ve known for a while that other research coming out of Purdue was highly suspect. TX & KS I’m not surprised, except that other states aren’t involved as well. Another example of great sleuthing, congrats Susan!

We would not accept these ethical/legal standards in medicine or law. The animal law sections of the various state bar associations should be contacted for assistance in lobbying and addressing this toxic issue.

Kinda the same thing???? Maybe a year ago in Tempe Arizona – at ASU University – a “big” pet store – brought over & sponsored a day of “playing with the puppies & dogs”. People fell for it. We all know most puppies in “pet stores” come from puppy mills. So sad to see this event.

In my opinion, this sounds in some ways similar to the human and environmental toxicity studies many Universities do for pesticide companies like Bayer and Monsanto as well as for drug clinical trials where the necessary studies are paid for by the companies and subsequently used for FDA and EPA approval. I’m not sure why there would be a greater health risk with pet foods if the required regulatory protocols were under complete state control (including public notification and hearings) and the samples used in laboratory compliance testing were coded and anonymous relative to the names, batches, dates and brands and ingredients of the tested foods.

Initially, it sounds more like administrative protocols need to be tightened and, of course, all test results in these states need to be made available to consumers and to the FDA as well as peer reviewed and published. FDA and state agencies have the ultimate regulatory authority and if there was collaboration between funding sources and universities that violated the rules, penalties and fines should be imposed on both institutions as well as disciplinary actions for participants. In all cases, confidentiality regarding the specific food and test results can not be used to deny public awareness. These are all publicly funded institutions.

Aside from the ‘conflict of interest’ … the Veterinary Nutrition courses taught in these Vet Schools are based on the product they are using … and these products are up for bid each year to the company who will supply the most feed with the most benefit to the CVM using it — poultry/large animal/domestic pets etc. .. and the courses on ‘Nutrition’ are only one semester quarter … and the ‘instructors are provided by the feed company (at least at NC State College of Veterinary Med)

Susan, thank you ever so much for your vigilance in exposing this CORRUPTION. At Kansas State Vet School, everywhere you look, you see Hills Science Diet signs, promotions, etc. I doubt there is a vet, who is ebucated at K State, that doesn”t promote Science Diet in their practice. Hmmmm, is there a connection? Duh, it doesn’t take a rocket scientist to figure out Hills is a big contributor to the education of those attending K State and thus, those students promote Science Diet once they become practicing vets. Thanks to people like you, who care and are genuinely concerned about our fur babies, I’ve learned to question and research, anything I feed my pet. Even at that, with all the CORRUPTION such as you just exposed to us, I still question if I’m feeding my baby what is best for her.

This is a swamp just like Washington D.C. I do not this is ethical. Shame on Universities that do this.
I went to my vet the other day and outside it was a Hill’s truck. My dog Gabriella was shaking, so I picked her up and said out loud don’t be scared I would never feed you that S**t. Then as I walked up to the door I noticed a man sitting by it. I am sure he heard me, and I really don’t care if he did. Pet food laws should be state and federally regulated, not by insiders.

Whoops, I meant this comment as a reply to Roberta Fox’s comment: “We would not accept these ethical/legal standards in medicine or law. The animal law sections of the various state bar associations should be contacted for assistance in lobbying and addressing this toxic issue.”

Whoops, I meant for this to be a replay to Roberta Fox’s comment: “We would not accept these ethical/legal standards in medicine or law. The animal law sections of the various state bar associations should be contacted for assistance in lobbying and addressing this toxic issue.”